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Home My WebLink About06-4539RICHARD WERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 06-'13'34 CIVIL TERM RAQUEL WERT, CIVIL ACTION - LAW Defendant IN CUSTODY 1. Plaintiff is Richard Wert, who currently resides at 598 Mountain Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Raquel Wert, who currently resides at 3206 Rimer Highway, Newville, Cumberland County, Pennsylvania 17241. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 21, 1997, in Cumberland County, Pennsylvania. 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. The Plaintiff seeks custody of the following child: Name Address DOB Tyler Wert 3206 Rimer Highway January 5, 2001 Newville, PA 17241 7. Tyler Wert was born in wedlock. 8. The child was in the primary custody of the Plaintiff, residing at 598 Mountain Road, Newville, Cumberland County, Pennsylvania 17241, until the time the Defendant filed for a Complaint for Child Support with Cumberland County Domestic Relations on June 30, 2006. 9. As of June 30, 2006, the child is in the primary custody of Raquel Wert, residing at 3206 Rimer Highway, Newville, Cumberland County, Pennsylvania, 17241. 10. After the Domestic Relations Hearing on July 25, 2006, the Mother relinquished custody of the child and the Father resumed primary custody of the child with him residing at 598 Mountain Road, Newville, Cumberland County, Pennsylvania, 17241. 11. During the child's lifetime, he has resided with the following persons and at the following addresses: Name Richard and Raquel Wert Richard Wert Raquel Wert Address 598 Mountain Road, Newville, PA 17241 598 Mountain Road, Newville, PA 17241 3206 Rimer Highway, Newville, PA 17241 Date Birth to March 1, 2005 March 1, 2005 to June 30, 2006 June 30, 2006 to July 25, 2006 Richard Wert 598 Mountain Road, July 25, 2006 to Present Newville, PA 17241 12. The father of the child is Richard Wert, who currently resides at 598 Mountain Road, Newville, Cumberland County, Pennsylvania, 17241. 13. The mother of the child is Raquel Wert, who currently resides at 3206 Rimer Highway, Newville, Cumberland County, Pennsylvania 17241. 14. The mother and father of the child are currently married. 15. The Defendant filed a Complaint for Divorce pursuant to Sections 3301(c) and (d) of the Divorce Code in the Court of Common Pleas of Cumberland County, Docket No. 2006-3368, Civil Term on June 13, 2006. 16. The Plaintiff fled Claims for Economic Relief in the Court of Common Pleas of Cumberland County, Docket No. 2006-3368, Civil Term on June 27, 2006. 17. The relationship of Plaintiff to the child is that of Father. 18. The relationship of Defendant to the child is that of Mother. 19. The Defendant currently resides with the following persons: Her child, Keith Sawdy (age 14), her mother and her step-father. 20. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or any other court. 21. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 22. The Plaintiff does not know of a person nor a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 23. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including the following. a. The Father has been the primary caregiver of the minor child since his birth. He has: i. Planned and prepared meals; ii. Bathed, groomed and dressed the child; iii. Purchased, cleaned and cared for the child's clothing; iv. Arranged medical care, including trips to physicians; v. Arranged alternative daycare; vi. Put the child to bed nightly, attended the child in the middle of the night, and awakened the child in the morning. b. The child has a psychological bond with the Father. C. Father is able to provide a stable environment for the child. d. It is believed and therefore averred that the Mother has picked the child up from daycare under the influence of alcohol on more than one occasion. e. It is believed and therefore averred that the Mother only maintained primary custody of the child from June 30, 2006, to July 25, 2006, in order to establish the required overnights so that she could receive child support payments from the Father. L Mother was awarded a monthly payment of $400.00 for child support. ii. However, since the July 25, 2006, Mother has relinquished primary custody back to the Father and he has maintained primary custody and care of the child. 24. Each parent whose parental rights to the child have not been terminated has been named as parties to this action. WHEREFORE, the Plaintiff requests that This Honorable Court grant primary physical custody of the child to the Plaintiff/Father. DATE IJTI VILA Respectfully submitted, ABOM & KUTULAK73, L.L.P. Q?- Michelle L. Sommei' Supreme Court ID 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff I, RICHARD WERT, verify that the statements made in this Custody Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. -?'o_ Date I?TCHARD WERT RICHARD WERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. NO. CIVIL TERM RAQUEL WERT, CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE AND NOW, this day AQJSZ?k 2006, I, Michelle L. Sommer, Esquire, of Abom & Kutulal is, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Custody Complaint, upon the Defendant's Attorney by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Douglas Miller Irwin & McKnight 60 [hest Pomfret Street Carlisle, Pennsylvania 17013 Respectfully submitted, AaOM & KUTUMMS, L.L.P. Michelle L. Somm Supreme Court ID 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney far Plaintiff V R1 a ?4 O Q ? dg G "D l t r' N_ G N N .C' RICHARD WERT IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 06-4539 CIVIL ACTION LAW RAQUEL WERT IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, August 14, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 21, 2006 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. 1/ d Custody Conciliator to The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ?, o4 • ,?, , W-Al V.NV lSNN3d MNnO') 'OIYIDgVMO s s -z Wd s 1 gnb 9002 AdViONOHICdd 3H1 dO 30Ua O-GMU A I RICHARD WERT, Plaintiff v RAQUEL WERT, Defendant SEP 2 6 2006 m? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4539 IN CUSTODY COURT ORDER c:,> e-TL') AND NOW, this 2 day of Septei er-1, 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed that the following temporary Custody Ordered is entered: 1. The father, Richard Wert, and the mother, Raquel Wert, shall enjoy shared legal custody of Tyler E. Wert, born January 5,2001. 2. Physical custody shall be handled as follows: a. The father shall have custody from every Saturday at 12:30 p.m. until Monday when the father shall deliver the child to either Kindergarten or Daycare. Additionally, father shall have custody of the minor child from every Tuesday when father gets off work until Thursday morning when father shall deliver the child to Kindergarten or Daycare. b. Mother shall have custody of the minor child at the times that the child is not in the father's custody. c. The parties may by agreement modify this schedule. Absent any agreement, the schedule set forth above shall control. t a• t -? ..i t1- 4 "?.0 Q'11) 7 ?Utr `t i "%t ?? ??u 11 11 A d. Each party shall enjoy a Right of First Refusal with respect to providing care for the minor child when the custodial parent is not available. This shall apply in circumstances when the custodial parent is not available for more than three hours to care for the child when they have custody because of that parent's work schedule or other commitments. In that situation, the custodial parent will contact the non-custodial parent and offer them the opportunity to provide daycare as needed. There is no obligation on the non-custodial parent to provide daycare in those situations, but the custodial parent must give the non-custodial parent first opportunity to provide daycare. 3. The parties shall meet for another Custody Conciliation on December 7, 2006 at 8:30 a.m. to discuss this Order and determine if a more permanent Order may be put into place. 4. On the Thanksgiving Holiday for 2006, the parties shall share the day with mother having custody from 9:00 a.m. until 3:00 p.m. and father having custody from 3:00 p.m. until 9:00 p.m. cc:iKara W. Haggerty, Esquire Ab'uglas Miller, Esquire BY THE COURT, RICHARD WERT, Plaintiff . v RAQUEL WERT, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4539 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Tyler E. Wert, born January 5, 2001. 2. A Conciliation Conference was held on September 21, 2006, with the following individuals in attendance: The father, Richard Wert, with his counsel, Kara W. Haggerty, Esquire, and the mother, Raquel Wert, with her counsel, Douglas Miller, Esquire. 3. The parties agree to the entry of an Order in the form as attached. DATE Hu rt X. Gilro , Esquire Custody Conci ' for RICHARD WERT, Plaintiff v RAQUEL WERT, Defendant DEC 18 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4539 IN CUSTODY COURT ORDER 'il? AND NOW, this day of December, 2006, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. /)w H ert X. ilroy, Esquire Custod onciliator d, A W t:J 1?c.A'di?? r 9 ? : I I I-IT 61 3-30 SUEZ I (JM ?' eU &s 36 South Hanover Street Carksle, Pennsylvania 17013 (717) 249-0900 RICHARD WERT, Plaintiff V. RAQUEL WERT, Defendant RAQUEL WERT, Plaintiff V. RICHARD WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4539 IN CUSTODY ? CIVIL ACTION -LAW IN CUSTODY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-3368 IN DIVORCE CIVIL ACTION - LAW IN DIVORCE MITION FOR RULE TO SHOW CAUSE AND NOW1 this 18th day of May, 2007, comes the Petitioner, ABOM & KUTULAKIS, L.L.P., by Kara W. Haggerty, Esquire, and Michelle L. Sommer, Esquire, and files this Petition for Rule to Show Cause, and represents as follows: 1. Petitioners are Kara W. Haggerty, Esquire, and Michelle L. Sommer, Esquire attorneys for Richard Wert, with offices at 36 South Hanover Street, Carlisle, Cumberland County, Pennsylvania. a 2. Respondent, Raquel Wert, who is represented by Douglas Miller, Esquire, of Irwin & McKnight, 60 West Pomfret Street, Carlisle, PA 17013. 3. Respondent, Richard Wert, resides at 598 Mountain Road, Newville, PA 17241. 4. Petitioners were retained on or about March 3, 2006, to represent Richard Wert in the above-captioned actions. 5. The parties presently have a Court Order signed by judge Oler on October 2, 20065 based on a custody conciliation that was held on September 21, 2006. 6. The parties are presently engaged in a divorce proceeding. 7. Petitioners drafted various pleadings in relation to the above-referenced custody and divorce matters, as well as engaged in correspondence with opposing counsel. 8. Richard Wert has not paid Petitioners in full for services rendered by the law firm to date. Although Petitioner has attempted to correspond with Richard Wert about his account and additional proceedings, those efforts have been unsuccessful. 9. Petitioners believe and therefore aver that Richard Wert has had adequate time to find substitute counsel and that neither party will be prejudiced should the court grant Petitioners' request herein. WHEREFORE, Petitioners respectfully requests This Honorable Court enter a Rule upon the Respondents to show cause why Petitioners should not be permitted to withdraw from this case as counsel for Richard Wert. Date: Respectfully Submitted, Kara W. Haggerty, Attorney ID #8691 36 South Hanover Street Carlisle, PA 17013 Petitioner l Date:' Michelle L. So r, Esquire Attorney ID #93034 36 South Hanover Street Carlisle, PA 17013 Petitioner AsOM & KUTULA"S.p L. L. P. VERIFICATION I, Kara W. Haggerty, Esquire, verify that the statements made in foregoing Petition for Rule to Show Cause are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DAB 05 11 b Im Kara W. Haggerty, Attorney ID #8691 VERIFICATION I, Michelle L. Sommer, Esquire, verify that the statements made in foregoing Petition for Rule to Show Cause are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE 51 IS 10i I A [ALARP Q PA- - M I IV I VUAMAX 'L I PA M&L Michelle L. Sommer, Esquire Attorney ID #93034 • . w CERTIFICATE OF SERVICE AND NOW, this 18t' day of May 2007, I, Kara W. Haggerty, Esquire, and Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that we did serve a true and correct copy of the foregoing Petition for Rule to Show Cause, upon Richard Wert and Raquel Wert's counsel by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Via Certified Mail - Return Receipt Requested. Richard M. [pert 598 Mountain Road Newtille, PA 17241 Via regular mail.- Douglas Miller, Esquire Iru in & McKnight 60 Kest Pomfret Street Carlisle, PA 17013 Kara W. Haggerty e I, AA A, . Ammw Michelle L. Sommer, Esquire 01 MAY 21 2001/ RICHARD WERT, Plaintiff v. RAQUEL WERT, Defendant RAQUEL WERT, Plaintiff V. RICHARD WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4539 IN CUSTODY ? CIVIL ACTION - LAW IN CUSTODY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-3368 IN DIVORCE CIVIL ACTION - LAW IN DIVORCE AND NOW, this Z 2 day of _ M -,) , 2007, upon petition of Kara W. Haggerty, Esquire, and Michelle L. Sommer, Esquire, a Rule is hereby issued upon the parties to show cause why the Petitioners should not be permitted to withdraw as counsel for Richard Wert. Rule returnable 120 days after the date of service of this Order. Service to be by certified mail upon Richard Wert and upon Raquel Wert's attorney of record, Douglas Miller, Esquire BY THE COURT: "Y n ? ? • I 1 INIV C Z )"u, ; `u W I00Z i IC-) -ABom & LUTLULAKIS 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 RICHARD WERT, Plaintiff V. RAQUEL WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4539 IN CUSTODY CIVIL ACTION - LAW IN CUSTODY RAQUEL WERT, Plaintiff V. . RICHARD WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-3368 IN DIVORCE CIVIL ACTION - LAW IN DIVORCE PETITION TO MAKE RULE ABSOLUTE 1. Undersigned counsel filed a Petition For Rule to Show Cause on May 18, 2007. 2. This Honorable Court issued an Order of Court for Rule to Show Cause on the parties herein on May 22, 2007. (Attached as Exhibit "A".) 3. As of June 5, 2007, no Answer was entered by either party. WHEREFORE, Petitioners respectfully requests This Honorable Court enter an Order making the Rule Absolute and granting Petitioners permission to withdraw as counsel for the Respondent. Date: 01Y OCo 1 Respectfully Submitted, ABOM & KUTUL4us; L. L. P. Hgqo L?. Kara W. Haggert, qui Attorney ID #86 36 South Hanover Street Carlisle, PA 17013 Petitioner Date: (1? Michelle L. Som r, Esquire Attorney ID #93034 36 South Hanover Street Carlisle, PA 17013 Petitioner VERIFICATION I, Kara W. Haggerty, Esquire, verify that the statements made in foregoing Petition for Rule to Show Cause are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE Lb up () I G Kara W. Haggerty Attorney ID #869 YL-4- VERIFICATION I, Michelle L. Sommer, Esquire, verify that the statements made in foregoing Petition for Rule to Show Cause are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE OdLLIR Michelle L. S mer, Esquire Attorney ID #93034 CERTIFICATE OF SERVICE AND NOW, this LO W day of June 2007, we, Kara W. Haggerty, Esquire, and Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that we did serve a true and correct copy of the foregoing Petition To Make Rule Absolute, upon Richard Wert and Raquel Wert's counsel by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Via Certified Mail - Return Receipt Requested: Richard M. Wert 598 Mountain Road Newvdle, PA 17241 Via regular mail. Douglas Miller, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, PA 17013 d%la . &VO) Michelle L. So mer, Esquire ?' c? ?, '?'1 ?y? ? ? LJ ? ? -! ) ? ? ?: ?? „? ? -{ r OM & U ULAKIS 36 Sonth Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 RICHARD WERT, Plaintiff V. RAQUEL WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4539 IN CUSTODY CIVIL ACTION - LAW IN CUSTODY RAQUEL WERT, Plaintiff V. RICHARD WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-3368 IN DIVORCE CIVIL ACTION - LAW IN DIVORCE TO THE HONORABLE J. WESLEY OLER, JR., JUDGE OF SAID COURT: AMENDMENT TO PETITION TO MAKE RULE ABSOLUTE 1. Undersigned counsel filed a Petition To Make Rule Absolute following an Order of Court dated May 22, 2007, issuing a Rule to Show Cause on undersigned counsel's Petition to Withdraw as Counsel. 2. The Honorable J. Wesley Oler, Jr., has previously ruled on custody and undersigned counsel's Petition to Withdraw as Counsel. 3. Undersigned counsel contacted Douglas Miller, Esquire, attorney for Plaintiff/Respondent, who indicated that he does not oppose counsel's request to withdraw as counsel. 4. As of June 5, 2007, no Answer was entered by either party. WHEREFORE, Petitioners respectfully requests This Honorable Court enter an Order making the Rule Absolute and granting Petitioners permission to withdraw as counsel for the Respondent. Date: L91 O& 1,9 Respectfully Submitted, ABOM & Ku=.4 ISM L. L. P. Kara W. Haggerty uire Attorney ID #86 36 South Hanover Street Carlisle, PA 17013 Petitioner Date: Michelle L. So r, Esquire Attorney ID #93034 36 South Hanover Street Carlisle, PA 17013 Petitioner AND NOW, this -b day of July, 2007, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P. hereby certify that I did serve a true and correct copy of the foregoing Amendment To Petition To Make Rule Absolute, upon Richard Wert and Raquel Wert's counsel by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Via Certified Mail - Return Receipt Requested.- Richard M. Wert 598 Mountain Road Neivville, PA 17241 Via regular mail.k Douglas Miller, Esquire Irvin d,' McKnight 60 Kest Pomfret Street Carlisle, PA 17013 Kara W. Haggerty r-? `-rat 4 '? S ? ?" i °i) ? ?? t _- .::r' ?.,; ?? ?? - r ? - .. .. ?,? ?: .. ?? JUN 09 P00P'? -ABOM & UTULAKIS 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 RICHARD WERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 06-4539 IN CUSTODY RAQUEL WERT, CIVIL ACTION - LAW Defendant IN CUSTODY RAQUEL WERT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 06-3368 IN DIVORCE RICHARD WERT, : CIVIL ACTION - LAW Defendant . IN DIVORCE ORDER TO MAKE RULE ABSOLUTE AND NOW, this q?r-' day of , 2007, a Rule to Show Cause having been issued on Respondent, Richard Wert, dated May 18, 2007, and Respondent failing to Answer, the RULE IS MADE ABSOLUTE. The 0 relief requested by Petitioner is hereby granted. Attorneys Kara W. Haggerty r: C 1, C")-c I C7 f 7 )-%461 1 and Michelle L. Sommer are granted permission to withdraw as counsel for the Respondent, Richard Wert. BY THE COURT: 1s I C? ?.?(.? Distribution: Kara W. Haggerty, Esquire Michelle L. Sommer, Esquire Douglas Miller, Esquire Richard M. Wert 598 Mountain Road Newville, PA 17241 0 OM & LITLILAKIS 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249.0900 RICHARD WERT, Plaintiff V. . RAQUEL WERT, . Defendant I ?Ult o820N? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-4539 IN CUSTODY \1Z CIVIL ACTION - LAW IN CUSTODY RAQUEL WERT, Plaintiff V. . RICHARD WERT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-3368 IN DIVORCE CIVIL ACTION - LAW IN DIVORCE ORDER TO MAKE RULE ABSOLUTE AND NOW, this A day of T 0 , 2007, a Rule to Show Cause having been issued on Respondent, Richard Wert, dated May 18, 2007, and Respondent failing to Answer, the RULE IS MADE ABSOLUTE. The relief requested by Petitioner is hereby granted. Attorneys Kara W. Haggerty I? :Z 14d 0 1 f P LOOZ and Michelle L. Sommer are granted permission to withdraw as counsel for the Respondent, Richard Wert. BY THE COURT: J? Distribution: Kara W. Haggerty, Esquire Michelle L. Sommer, Esquire Douglas Miller, Esquire / ? I - r r Richard M. Wert 598 Mountain Road Newville, PA 17241 a